M&A Tax Counsel

IBM is a leader in worldwide transformation and just the place to further define and develop your career in Tax. Our dedicated teams of business professionals give our clients more than solutions – we ask, "what else is possible?". As a member of our IBM Tax team, you'll have the opportunity to grow your expertise with a market leader, while exploring and connecting with virtually every part of IBM, in over 160 countries.
When you join IBM, you join a culture of openness, collaboration, and trust. Join us and experience a place where you can co-create your learning and opportunities. A place where teamwork and unique ideas are treasured. A place where you can bring innovation to life.
We are seeking an experienced Mergers & Acquisition Tax Specialist for IBM's corporate tax department. The selected candidate will advise our Corporate Development and Business Development groups with respect to acquisitions, dispositions and joint venture opportunities. The candidate will be involved throughout the deal life cycle, from opportunity identification through deal execution and integration. The ideal candidate should have strong tax technical skills in areas such as:
Cross-border M&A
Subchapter C, including section 367
TCJA
Subpart F income
The US foreign tax credit system
Pillar 2 rules